AUSTRAC Tranche 2 AML/CTF Obligations (2026)
Under Tranche 2 reforms, accountants and tax agents who handle client funds, trust accounts, or financial transactions are now captured under the AML/CTF Act. This page explains exactly what you must do to comply.
Learn more in the AML/CTF Guide.
You are captured if you provide any **designated service**, including:
Managing client funds or trust accounts
Handling payments, transfers, or financial transactions
Providing instructions for financial dealings
Acting as an intermediary in transactions
Providing services that involve high‑risk clients
Assisting with company or trust formation
If you perform any of these activities, you must comply with the AML/CTF Act — even if you are a sole trader or small practice.
You must maintain a written AML/CTF Programme that explains your governance, risk assessment, controls, and CDD procedures.
You must assess the money laundering and terrorism financing risks associated with your clients, services, and delivery channels.
You must verify client identity, understand their purpose, and apply enhanced due diligence for high‑risk clients.
You must report suspicious matters to AUSTRAC within 3 business days (or 24 hours for terrorism‑related matters).
You must keep AML/CTF records, CDD evidence, and SMR logs for at least 7 years.
You must monitor client activity, update risk assessments, and review your AML/CTF Programme annually.
See full requirements in the AML/CTF Guide.
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